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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
1 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
Payment Processors
HSBC Bank Plc (UK, Ireland), HSBC Merchant
Services LLP (UK), Bank of America (UK, USA,
Italy, and India), Discover Financial Services
(USA), JPMorgan Chase Bank (UK, USA), BNP
Paribas (France), Netgiro (Sweden), StarFinanz
(Germany), Wells Fargo (Ireland, USA),
American Express (USA), National Westminster
Bank PLC (UK), OmniPay Limited (Ireland),
Australia and New Zealand Banking Group
Limited (Australia), ANZ National Bank Limited
(New Zealand) and Transaction Network
Services (UK) Limited (UK)
To allow payment
processing
settlement
services, and fraud
checking.
Name, address,
details of user funding
instruments, and
details of payment
transactions
Deutsche Bank AG (Germany, Netherlands,
France, Spain)
To allow the
processing of
direct debits in
Germany,
Netherlands,
France and Spain.
Name, date of
transaction, amount,
currency and user’s
bank account
information.
Royal Bank of Scotland plc (UK) (“RBS”)
To allow payment
processing and
dispute handling
for transactions of
PayPal users when
those users
transact with a
merchant who
uses the PayPal
service via the
RBS service.
All account information
except details of user
financial instruments.
Visa Europe Ltd (UK) including Visa’s VMAS To share risk and All account details of
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
2 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
system; Mastercard International Incorporated.
(USA) including Mastercard’s MATCH system
fraud information in
the mandatory
credit card
company’s
database regarding
the conduct of a
merchant’s
account thereby
reducing exposure
to fraud and
breaches of
scheme rules and
standards.
merchant account, and
circumstances and
conduct of the account
Global Payments UK LLP (UK)
To allow payment
processing, fraud
checking and
dispute handling
for transactions of
PayPal users when
those users
transact with a
merchant who
uses the PayPal
service via the
Global Payments
service.
Name, address,
details of user funding
instruments and
details of payment
transactions
WorldPay (UK) Limited, Worldpay AP Limited,
(UK) Worldpay . (The Netherlands)
To allow payment
processing, fraud
checking and
dispute handling
for transactions of
PayPal users when
those users
All Account
information except
details of user financial
instruments
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
3 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
transact with a
merchant who
uses the PayPal
service via
Worldpay service.
American Express Travel Related Services
Company, Inc.
To allow payment
processing
settlement
services, and fraud
checking.
Unique Seller ID.
Seller MCC
Seller DBA
Authorized signer
Seller address, postal
and country code
Seller phone number
Seller email address
Seller URL
Date of birth (for sole
proprietors only)
For non-publicly
traded Sponsored
Merchants only (e.g.
privately held
company, sole
proprietor), the
following information
for a Significant Owner
(as defined below):
First and last
name
Home
address,
postal code
and country
code
SSN or date of
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
4 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
birth
Significant owner
means an individual
who has 25% or
greater ownership of a
business.
Unique seller ID*
Sponsored Merchant
MCC
Sponsored Merchant
DBA
Sponsored Merchant
location (city, street,
postal code and
country code)
Sponsored Merchant
phone number
JPMorgan Chase Bank, N.A. London Branch
Anti-money
laundering,
sanctions list
checking and
compliance checks
Name of merchant,
country of domicile,
and business activity
Adyen B.V. (Netherlands)
To allow payment
processing and
settlement services
globally.
Name, address,
details of payment
instruments, and
details of payment
transactions.
Allied Irish Bank PLC (UK)
To allow payment
processing and
settlement services
in Europe.
Name, address,
details of payment
instruments, and
details of payment
transactions.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
5 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
Cardinal Commerce Corporation (US)
To facilitate
3DSecure
checking for
payment
processing
globally.
Standard transaction
data for 3DSecure.
Coinbase Inc. (US)
To allow payment
processing and
settlement services
globally.
Name, address,
details of payment
instruments, and
details of payment
transactions.
Heartland Payment Systems, Inc. (USA)
To allow payment
processing and
settlement services
in the United
States.
Name, address,
details of payment
instruments, and
details of payment
transactions.
Merchant e-Solutions, Inc. (US)
To allow payment
processing and
settlement services
in the United
States.
Name, address,
details of payment
instruments, and
details of payment
transactions.
Moneris Solutions Corporation (Canada)
To allow payment
processing and
settlement services
in Canada.
Name, address,
details of payment
instruments, and
details of payment
transactions.
National Australia Bank Ltd. (Australia)
To allow payment
processing and
settlement services
in Australia.
Name, address,
details of payment
instruments, and
details of payment
transactions.
Network Merchants, LLC. (US); Network To allow payment Name, address,
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
6 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
Merchants Inc. (US) processing and
settlement services
in the United
States.
details of payment
instruments, and
details of payment
transactions.
Stockholms Enskilda Bank AB (Sweden)
To allow payment
processing and
settlement services
in Europe.
Name, address,
details of payment
instruments, and
details of payment
transactions
WorldPay, Inc. (US); WorldPay Ltd. (UK)
To allow payment
processing and
settlement services
globally.
Name, address,
details of payment
instruments, and
details of payment
transactions.
Audit
PricewaterhouseCoopers Sàrl (Luxembourg)
To test PayPal’s
Anti Money
Laundering (AML)
and Know Your
Customer (KYC)
controls and to
carry out
professional
auditing services
for PayPal Inc. and
its subsidiaries.
For a sample of
individual customer
accounts:
name, PayPal account
number (Customer
ID), total amount
received on the
PayPal account, total
amount sent from the
PayPal account, type
of PayPal account,
and, as the case may
be, any other relevant
account information.
Customer Service Outsourcing
Sutherland Global Services Inc. (USA and
Philippines), Sitel GmbH (Germany), Transcom
To allow telephone
and email
Name, address, phone
number, email
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
7 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
Worldwide SAS (France, Tunisia), Transcom
Worldwide France SAS (France), Transcom
Worldwide SpA (Italy), Competence Call Center
Leipzig GmbH (Germany), Convergys Customer
Management Group Inc. (USA), Arvato Direct
Services GmbH (Germany) and Concentrix
Europe Limited (UK)
customer support
services.
addresses, truncated
and limited or full
funding source
information (case
dependent), funding
source expiration
dates, type of PayPal
account, proof of
identity, account
balance and
transaction
information, customer
statements and
reports, account
correspondence,
shipping information,
and promotional
information.
Nuance Communications Inc. (USA)
To calibrate and
optimise speech
recognition
performance for
telephone
customer support
services.
Recordings of a
sample of customer
support telephone
calls, which may
include any or all
account information
transmitted during the
call.
ICT Group Inc. (US)
To perform and
facilitate telephone
customer support.
Name, address, phone
number, and PayPal
account number.
Lithium Technologies Inc. (USA)
To provide
member-to-
member platform
Name, email address,
PayPal single sign on
ID (PayPal SSN ID)
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
8 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
services and
customer service
on our customer
community
platforms.
Attensity Europe GmbH
To provide
customer services
arising from
customer contacts
to PayPal on social
media channels.
Information provided
by the customer via
social media channels
which may include
name, address, phone
number, email
addresses, social
media user names,
truncated and limited
or full funding source
information (case
dependent), funding
source expiration
dates, type of PayPal
account, proof of
identity, account
balance and
transaction
information, customer
statements and
reports, account
correspondence,
shipping information,
and promotional
information.
ILinc Communications, Inc. (USA)
To provide
webinars (online
seminars) to
Name, email address
of merchants
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
9 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
merchants on
ILinc’s platform.
ePerformax Contact Centers & BPO (USA),
Genpact International Inc. (USA), LatentView
Analytics Pte. Ltd
To provide
customer services
regarding
payments globally.
Name, address, phone
number, email
addresses, truncated
and limited or full
funding source
information (case
dependent), funding
source expiration
dates, type of PayPal
account, proof of
identity, account
balance and
transaction
information, customer
statements and
reports, account
correspondence,
shipping information,
and promotional
information.
Authentify Inc.
Telephony based
authentication
service
Mobile and land-line
phone numbers
CallPoint New Europe AD dba TELUS
International Europe (Bulgaria)
To operate
refunded returns
service.
Name, email address,
PayPal transaction ID,
return information
(returned item
category, reason for
return, amount of
return, currency,
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
10 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
country of return, type
of return) and shipping
documentation
evidence.
Key Performance Group SAS, France
Administration of
PayPal member
referral program
First name, last name,
email, customer ID,
transaction information
related to referral
rewards
New Relic, Inc. (US)
To provide
analytics allowing
us to troubleshoot
errors in the
service globally.
Log Data and
Aggregated data on
the service
performance.
PagerDuty, Inc. (US)
To alert on-call
technicians that an
email has arrived
globally.
Subject of the Email at
issue.
Sumologic, Inc. (US)
To provide
analytics allowing
us to troubleshoot
errors in the
service globally.
Log Data and
Aggregated data on
the service
performance.
Credit Reference and Fraud Agencies
Please note that in addition to the stated purposes below, PayPal uses your personal information to
detect, prevent, and/or remediate fraud or other illegal actions, or to detect, prevent or remediate
violations of policies or applicable user agreements.
CRIF (Italy), Cerved B.I (Italy), Coface (France),
Synectics Solutions Limited (UK), MCL Hunter
(UK), GB Group plc (UK), Graydon (UK), Capita
Plc (UK),UK Data Limited (UK), ICC Information
To verify identity,
verify linkage
between a
customer and its
Name, address, phone
number, email
address, date of birth,
length of time at
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
11 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
Limited (UK), Payment Trust Limited (UK),
192.com (UK), 192.com Limited (UK), i-CD
Publishing (UK) Limited (UK), Experian
Netherlands BV (Netherlands), Experian Bureau
de Credito SA (Spain), Informa D&B SA (Spain),
and CRIBIS D&B S.r.l. (Italy).
bank account or
credit/debit card,
assist in making
decisions
concerning a
customer’s credit
worthiness
(including without
limitation, in
relation to credit
products offered by
PayPal), carry out
checks for the
prevention and
detection of crime
including fraud
and/or money
laundering, assist
in debt recovery,
manage PayPal
accounts and
undertake
statistical analysis,
undertake research
and testing as to
appropriateness of
new products and
services and
system checking.
Please note that
data disclosed to
these agencies
address, proof of
identity, legal form,
length of time in
business, company
registration number,
VAT number, funding
instrument including
bank account and
credit /debit card
details (if appropriate)
and relevant
transaction information
(if appropriate).
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
12 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
may be retained by
the applicable
credit reference
and fraud agency
for audit and fraud
prevention
purposes.
Callcredit plc. (UK) including the SHARE
database administered by Callcredit, Experian
Limited (UK) including databases administered
by Experian used for consumer and commercial
referencing including CAPS credit searches and
CAIS credit account performance data, Equifax
Ltd (UK) including the Insight database
administered by Equifax, Dun & Bradstreet
Limited (UK)
To verify identity,
verify linkage
between a
customer and its
bank account or
credit/debit card,
make decisions
concerning a
customer’s credit
worthiness
(including without
limitation, in
relation to credit
products offered by
PayPal), carry out
checks for the
prevention and
detection of crime
including fraud
and/or money
laundering, assist
in debt recovery,
manage PayPal
accounts and
undertake
statistical analysis,
Name, address, phone
number, email
address, date of birth,
length of time at
address, proof of
identity, legal form,
length of time in
business, company
registration number,
VAT number, funding
instrument including
bank account and
credit /debit card
details (if appropriate),
relevant transaction
information (if
appropriate), account
balance, all
information supplied
and used for your
application for the UK
products “Website
Payments Pro”,
“Virtual Terminal” and
“PayPal Here” and the
financial instrument
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
13 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
undertake research
and testing as to
appropriateness of
new products and
services and
system checking.
For users of the
UK products
“Website
Payments Pro”,
“Virtual Terminal”
and “PayPal Here”
and UK merchants
only:
• to report defaults
and supply monthly
account
performance
information, where
the account shows
an amount owing
to us (reflected as
a negative
balance) for three
or more
consecutive
months, to the
databases of these
third parties; and
• for the purposes
set out in section 8
of this Privacy
used to pay for your
PayPal Here- enabled
device.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
14 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
Policy.
Please note that
data disclosed to
these agencies
and databases
may be:
• retained by the
applicable credit
reference agency
or database for
audit and fraud
prevention
purposes;
• disclosed to other
financial
institutions for the
purpose of gauging
creditworthiness;
and
• transferred
outside of the EU
and on a global
basis.
CIFAS (UK) and the CIFAS database
For users with UK
PayPal accounts
only: to prevent
and detect fraud
(which may include
checking details on
job applicants and
employees and on
proposals and
All account details and
circumstances of the
conduct of the account
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
15 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
claims for all types
of insurance).
Please note that
data disclosed to
this database may
be:
• retained by the
database for audit
and fraud
prevention
purposes;
• disclosed to other
financial
institutions for the
purpose of fraud
prevention and
detection (including
to prevent money
laundering) for
example, when
checking details on
applications for
credit and other
facilities, managing
credit and credit
related accounts or
facilities,
recovering debt,
checking details on
claims for
insurance and
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
16 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
checking details of
job applicants or
employees;
• used to
determine your risk
profile and for
cooperation with
the relevant
authorities in
compliance with
the requirements of
the Luxembourg
Law of 5 April 1993
on the financial
sector and laws
relating to the
prevention of
money laundering,
terrorism and fraud
(excluding the
treatment of
personal data in
relation to solvency
of the persons
referred to in article
14(1)(d) of the
Luxembourg Law
of 5 April 1993 on
the financial
sector); and
• transferred
outside of the EU
and on a global
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
17 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
basis.
DueDil Limited (UK)
To receive
business
information for risk
assessment, and
compliance with
anti-money
laundering
requirements, such
as establishing the
corporate structure
and beneficial
ownership.
Company registration
number, name and
address of business,
name, address, date
of birth of directors.
Creditsafe USA Inc. (USA)
To receive
business
information for risk
assessment, and
compliance with
anti-money
laundering
requirements, such
as establishing the
corporate structure
and beneficial
ownership.
Company registration
number, name, and
address of business,
name, address, date
of birth of directors
Deltavista GmbH (Germany)
Establish risk
associated with
address, identity;
assist in making
decisions
concerning a
customer’s credit
Name, address, date
of birth, email address
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
18 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
worthiness;
research and
testing as to
appropriateness of
new products and
services.
Accumio Finance Services GmbH (Germany),
CEG Creditreform Boniversum GmbH
(Germany), Bürgel Wirtschaftsinformationen
GmbH & Co. KG (Germany)
To verify identity
and address and
retrieve contact
phone numbers
and addresses,
establish risk
associated with
address, identity;
research and
testing as to
appropriateness of
new products and
services.
To assist in making
decisions
concerning the
credit worthiness of
consumers (if they
have a German
PayPal account
and have
specifically
consented to such
check) and
merchants,
including without
limitation, in
Name, address, date
of birth, email address,
account status,
account balance, and
in case the transfer of
such information is
legally justified, also
certain information on
negative account
performance of a
customer with a
German PayPal
account, for which
PayPal has requested
a creditworthiness
check from the
respective database.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
19 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
relation to credit
products offered by
PayPal and
offering direct debit
payments as
payment method.
The
creditworthiness
scores that we
request from these
agencies that
include scores that
are calculated
according to
mathematical-
statistical
procedures.
Please note the
fact that PayPal
requested such
information, and
any negative
account
performance data
disclosed to these
databases in
relation to
customers who
have a German
PayPal account
may potentially be:
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
20 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
• retained by the
database for audit
purposes and for
scoring of such
customer’s
creditworthiness;
• any such score
may be disclosed
to other third
parties for the
purpose of gauging
creditworthiness.
and
• transferred
outside of the EU
and on a global
basis.
SCHUFA Holding AG (Germany), infoscore
Consumer Data GmbH (Germany)
To verify a
customer's identity
and address, carry
out checks for the
prevention and
detection of failing
direct debit
payments, and of
crime including
fraud and/or
money laundering,
including checks
on the linkage of
the customer and
its bank account, to
help determine
Name, address, email
address, date of birth,
gender, bank account
details, information on
failed direct debit
payments from a bank
account (without
linkage to the identity
of the customer), and
in case the transfer of
such information is
legally justified, also
certain information on
negative account
performance of a
customer with a
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
21 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
creditworthiness of
consumers (if they
have a German
PayPal account
and have
specifically
consented to such
check) and of
merchants, and for
research and
testing as to
appropriateness of
products and
services.
The
creditworthiness
scores that we
request from these
agencies include
scores that are
calculated
according to
mathematical-
statistical
procedures.
Please note the
fact that PayPal
requested such
information, and
any negative
account
performance data
disclosed to these
German PayPal
account.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
22 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
databases in
relation to
customers who
have a German
PayPal account
may potentially be:
• retained by the
database for audit
purposes and for
scoring of such
customer’s
creditworthiness;
• any such score
may be disclosed
to other third
parties for the
purpose of gauging
creditworthiness
and
• transferred
outside of the EU
and on a global
basis.
Further, in relation
to customers who
have a German
PayPal account,
the information on
a failed direct debit
payment may be:
• retained by the
infoscore database
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
23 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
for audit purposes;
and
• (without linkage
to the customer’s
identity) disclosed
to other third
parties for the
purpose of
preventing failed
direct debit
payments.
Creditreform Berlin Wolfram KG (Germany),
Verband der Vereine Creditreform e.V.
(Germany)
To determine
creditworthiness of
merchants.
Name, address, email-
address.
World-Check (UK) To verify identity.
All account
information.
Global Data Corporation (USA)
To verify identity,
carry out checks
for the prevention
and detection of
crime including
fraud, research
and testing as to
appropriateness of
new products and
services.
Name, address, date
of birth, telephone
number, email address
RSA Security Inc. (USA) and RSA Security
Ireland Limited (Ireland) To verify identity.
All account
information.
ID Checker.nl BV (Netherlands) (Ireland)
To verify identity;
automatic data
extraction from
images of
Name, address, email
address, date of birth,
legal form, company
registration number,
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
24 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
documents, and
document
validation / forgery
detection.
Research and
testing as to
appropriateness of
new products and
services.
VAT number, proof of
identity, address,
ownership of a funding
instrument or other
documents requested
by PayPal and the
data contained therein
for Risk / Compliance/
Credit purposes.
Aristotle International, Inc. (USA) To verify identity.
Name, address, date
of birth
Acxiom Ltd (UK), Acxiom Deutschland GmbH
(Germany) and Acxiom France SAS (France) To verify identity.
Name, address, phone
number, email address
and date of birth.
Creditinfo Decision (Czech Republic) and
DecisionMetrics Limited (UK)
To assist with
PayPal’s
assessment of
merchant risk.
All merchant account
information.
ThreatMetrix Inc (USA)
To retrieve risk
information
regarding the IP
and device from
which you are
accessing PayPal,
research and
testing as to
appropriateness of
new products and
services.
IP and hardware
information about the
device (device ID)
TeleSign Corporation (USA)
To validate phone
numbers, research
and testing as to
Telephone number
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
25 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
appropriateness of
new products and
services.
AddressDoctor GmbH (Germany),
To re-structure
address data into
normalized format.
Name, address, email
address
Deutsche Post Direkt GmbH (Germany), AZ
Direct GmbH (Germany), Deutsche Post Adress
GmbH & Co. KG (Germany)
To validate and re-
structure address
data into
normalized format
and to verify name
and address.
Name, address, email
address
Mitek Systems Inc. (USA)
To validate images
of identity
documents and
research and
testing as to
appropriateness of
new products and
services.
Proof of identity,
details of bank
accounts and
credit/debit card
information
Jumio Inc (USA)
To capture and
validate proofs of
identity and
address
All data recorded on
the customer’s identity
and address
documents
Au10tix Limited (Cyprus), AuthenticID LLC
To verify identity;
automatic data
extraction from
images of
documents,and
document
validation / forgery
detection.
Name, address, email
address, date of birth,
legal form, company
registration number,
VAT number,
documents proving
identity and address,
ownership of a funding
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
26 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
Research and
testing as to
appropriateness of
new products and
services.
instrument, or other
documents requested
by PayPal and the
data contained therein
for Risk / Compliance/
Credit purposes.
Telovia SA (Luxembourg)
Identity validation
and Know Your
Customer (KYC)
controls conducted
for anti money
laundering
purposes
Name, address, date
of birth, proof of ID
and address
Syniverse Technologies, LLC (USA)
Validate and apply
data quality checks
to phone numbers
(SMS message to
be sent to the
customer)
Name, address, phone
number.
Signicat AS (Norway)
To verify and
authenticate
identity
Name, address, date
of birth and e-id
reference number
BankersAccuity Inc. (USA)
Research and
testing as to
appropriateness of
new products and
services in relation
to the validation of
the account data
provided to us by
the user and
conversion of
Customer’s bank
account number and
sort code and / or
IBAN
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
27 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
national account
data information
into IBAN
ArkOwl LLC (USA)
To verify email
address Email address
Fraudscreen Ltd (UK)
To evaluate level
of fraud risk Name and address
LexisNexis, LexisNexis Risk Solutions UK
Limited (UK)
To assist with
customer
authentication
Name, address and
date of birth
Trustev Ltd (Ireland)
To establish
identity through
customer’s social
media data,
connections and
credentials
Name, address, date
of birth, email address
and account number
Tracesmart Ltd (UK)
To identify
customers and
assist with fraud
detection,
prevention, and or
remediation of
fraud, or other
illegal actions or to
detect, prevent or
remediate
violations of
policies or the
applicable user
agreements.
Title, name, address,
date of birth and
telephone number
Zoot Enterprises, Inc. (USA), Zoot Deutschland
GmbH (Germany), Zoot Enterprises Limited
To process
technical
All account information
and documents
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
28 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
(UK) applications and to
provide a data and
document gateway
for account review,
testing and vetting
purposes, and to
exchange user
information and
images of
documents proving
identity, address
and ownership of
funding instrument
with contracted
fraud and credit
reference
agencies. To also
aggregate data
from internal and
external data
sources and
provide statistical
analysis in order to
assess the risk of
fraud.
supplied by
customers, to include
information used to
provide identity and
address, ownership of
a funding instrument,
or other documents
requested by PayPal
and the data
contained therein for
Risk / Compliance /
Credit purposes. This
information may also
include IP addresses.
First Data Corporation (USA)
To process
merchant-initiated
and customer-
authorized
transactions and to
provide
account/card
processing
All account information
and documents
supplied by
customers, to include
information used to
provide identity and
address.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
29 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
services, to store
transaction,
payment and other
customer data
related to those
transactions.
La Banque de France (France), GB Group plc
(UK), SysperTec Communication (France)
Research and
testing as to
appropriateness of
new products and
services used to
establish risk
associated with
address, identity,
and associated
with a customer’s
credit worthiness.
Name, address, date
of birth, phone
number, email address
MaxMind, Inc. (USA)
To detect fraud.
Please note that
data disclosed to
this service
provider may be:
• retained by it for
audit and fraud
prevention
purposes;
• used by it for the
purpose of
optimising its fraud
detection services
provided to PayPal
and other third
parties; and
All account information
and IP address, credit
card information.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
30 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
• transferred
outside of the EU
and on a global
basis.
Future Route Ltd (UK)
To carry out
accounting data
analysis of our
commercial users
for real time credit-
risk evaluation.
Name, address, email
address and date of
birth.
Kount, Inc. (US)
To facilitate fraud
checking for
payment
processing
globally.
Name, address,
device fingerprint data,
details of payment
instruments, and
details of payment
transactions.
Artefacts Solutions LLC (US)
To detect fraud
and mitigate risk
related to
transaction
processing.
Truncated card
number, amount of
transaction,
chargeback ratio,
credit ratio, and
decline ratio.
Experian Information Solutions, Inc. (US)
To verify identity,
assist in making
decisions
concerning a
customer’s credit
worthiness, carry
out checks for the
prevention and
detection of crime
including fraud
and/or money
laundering.
Please note that
Name, address, social
security number, date
of birth, business
name, legal name of
business, tax ID,
business phone
number.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
31 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
data disclosed to
these agencies
may be retained by
the applicable
credit reference
and fraud agency
for audit and fraud
prevention
purposes.
Trulioo Information Services, Inc. (US)
To verify identity,
carry out checks for
the prevention and
detection of crime
including fraud
and/or money
laundering.
Please note that
data disclosed to
these agencies
may be retained by
the applicable
credit reference
and fraud agency
for audit and fraud
prevention
purposes.
Name, date of birth,
address, ID number (if
provided).
Financial Products
La Poste (France)
To resolve
technical issues
and user claims
(when PayPal is
being offered by
the merchant
through La Poste’s
Any Account
information necessary
to resolve the issue or
claim
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
32 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
payment solution).
Santander UK Cards Limited (UK)
To conduct joint
marketing
campaigns for
PayPal Credit, and
PayPal
MasterCard, risk
modelling, enforce
terms and
conditions for
PayPal Credit and
PayPal
MasterCard.
Name, address, email
address and account
information (including,
without limitation,
account status).
TSYS Card Tech Limited (UK), TSYS Managed
Services EMEA Limited (UK), PrePay
Technologies Limited (trading as PrePay
Solutions) (UK)
To conduct joint
marketing
campaigns for
PayPal pre-paid
card and risk and
fraud modelling
and to enforce
terms and
conditions for
PayPal prepaid
card.
Name, address, email
address, date of birth
and account
information.
Société Générale (France), La Banque Postale
(France), BNP Paribas (France) and Crédit
Mutuel (France)
Billing purposes.
Only for merchants
using PayPal through
the partner’s payment
solution: merchant ID,
number of PayPal
transactions,
transaction volume
with PayPal and, as
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
33 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
the case may be,
termination of the
PayPal account.
Findomestic Banca (Italy), Cetelem S.A., Cofidis
(France) and Cofinoga S.A. (France)
Registration of the
credit card issued
by the credit
company on the
user’s PayPal
account and the
processing of
funding requests
made by the same
user.
Name, email address,
date of birth (as the
case may be), credit
card number, expiry
date, three digit Card
Security Code (as the
case may be) and
amount of the funding
request and any
account information
necessary for fraud or
dispute resolution.
Total System Services, Inc. (USA)
To process
merchant initiated
and customer
authorised
payments
(including
customer direct
debit information)
to provide
account/card
processing
services, to store
transaction,
payment and other
customer data
related to those
transactions. To
provide call centre
Name, address, email
address, date of birth
(where required), all
account information
and documents
supplied by
customers, to include
information required to
prove identity and
address.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
34 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
services, card
printing, and
statement printing
services.
United Kapital Limited (UK) and United Kapital
Limited, LLC (USA)
To enable you (or
the merchant with
which you transact)
to use products
issued by United
Kapital with
PayPal.
Only for PayPal
merchants applying for
and using products
issued by United
Kapital Limited: Name,
business name,
address, date of birth,
copies of identification
documents, PayPal
identification
(merchant ID), email
address, phone
number, transaction
information (including,
without limitation,
number of PayPal
transactions and
transaction volume
with PayPal), length of
time as a PayPal user
and, as the case may
be, termination of the
PayPal account.
For customers of
those merchants:
transaction
information, name,
email address, phone
number, address and
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
35 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
PayPal identification
number.
Commercial Partnerships
Royal Mail Group Plc. (UK) and Pitney Bowes
Inc. (USA)
To provide
automated label
printing for sellers
using PayPal and
eBay to facilitate
postal and delivery
services, including
payment
reconciliation
services.
Name, address, email
address and postage
transaction amount.
Trustwave (USA)
To provide
customised
services and
assistance to
Merchants using
PayPal, and to
facilitate the
process of
becoming PCI DSS
compliant.
Name, email address
and PayPal account
number.
Stubhub Services S.à.r.l. (Luxembourg)
For the purposes
of its AML and
KYC requirements.
First and last name,
date of birth,
residential address,
nationality, national
ID/passport number
Marketing and Public Relations
Decipher Inc. (USA), Northstar Research
Partners (USA)
To conduct
customer service
surveys.
Name, email address,
type of account, type
and nature of the
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
36 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
PayPal services
offered or used, and
relevant transaction
information.
Ipsos Mori UK Limited (UK), Ipsos GmbH
(Germany), Ipsos SAS (France) and FactWorks
GmbH (Germany), TNS Deutschland GmbH
(Germany)
To conduct
customer service
and marketing
surveys.
Name, email address,
phone number, type of
account, type and
nature of the PayPal
services offered or
used, and relevant
transaction
information.
Adwise (France) and Axance (France)
To conduct
marketing surveys.
Name, email address,
phone number, type of
account, type and
nature of the PayPal
services offered or
used, and relevant
transaction
information.
BD Network Limited (UK), Tullo Marshall Warren
Limited (UK), and MyCash (France)
To develop and
execute customer
promotions.
Name, address and
email address.
Salesforce.com, inc. (USA)
To store merchant
contact information
as well as other
supporting
information about
the business
relationship.
Name, address, phone
number and email
address, business
name, URL PayPal
Account ID and other
supporting information
about the business
relationship, such as
(without limitation)
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
37 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
name of contact
person and contact
information at
merchant and/or
partner through which
merchant has been
onboarded, description
of products sold
through PayPal,
communication notes
and onboarding
information, internal
decisions about the
merchant, revenue
calculations and other
information on the
merchant’s business
as made available by
the merchant, and
information relevant
for special integrations
of merchants, name
and address of bank.
Daniel J Edelman Ltd (UK), I&E Consultants
(France), Grayling Communications Limited
(UK), Rock Communications (Italy), Fleisher
(Israel), Clue PR (Poland).
To answer media
enquiries regarding
customer queries.
Name, address, and
all customer account
information relevant to
customer queries.
Alchemy Worx Ltd (UK)
To allow
management
reporting of
marketing
campaigns.
Name, email address
and details of
customer campaign
interaction.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
38 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
Carrenza Limited (UK)
To store user data
for marketing
campaigns.
Name, address, email
address, business
name, domain name,
account status,
account preferences,
type and nature of the
PayPal services
offered or used, and
relevant transaction
information.
1000Mercis SA (France) and 1000Mercis Ltd
(UK)
To store user data
to conduct
marketing
campaigns on
behalf of PayPal.
Name, email address,
phone number, type of
account, type and
nature of the PayPal
services offered or
used, and relevant
transaction
information.
A McLay & Company Limited (UK), TNT Post
Italia (Italy)
To assist in the
execution of offline
direct mail and
marketing
campaigns.
Name, address, email
address, business
name, domain name,
account status,
account preferences,
type and nature of the
PayPal services
offered or used, and
relevant transaction
information.
Datacolor Dialog-Medien GmbH (Germany),
MEILLERGHP GmbH (Germany) and W & J
Linney Ltd (UK)
To assist in the
execution of offline
direct mail and
marketing
Name, email address,
address, business
name, domain name,
account status,
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
39 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
campaigns. account preferences,
type and nature of
PayPal services
offered or used.
Medallia, Inc. (USA)
To conduct
customer service
surveys.
Name, email address,
type of account, type
and nature of the
PayPal services
offered or used, and
relevant transaction
information.
Endlichsommer- werbung in bester gesellschaft
mbh (Germany) and Crossover Communication
GmbH (Germany)
To assist in the
execution of offline
direct mail and
marketing
campaigns
Name, address,
business name, type
and nature of PayPal
services offered or
used.
optivo GmbH (Germany)
To send emails;
email marketing
Name of the merchant,
name of the contact
person, email address,
address, status, client
ID and shop system
Acxiom France SAS (France), Acxiom Ltd (UK)
and Acxiom GmbH (Germany)
To collect
additional user
information and
better target
marketing
campaigns.
Name, address, email
address, date of birth
and phone number.
Rapp (France), Antics (US), Partner Path
To develop,
measure and
execute marketing
campaigns.
Name, business
name, address and
registration number of
merchant/partner,
name, job, title, email
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
40 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
address, phone
number of merchant’s
contact person,
merchant website
URL, PayPAl account
number, third party
applications used by
the merchant,
behaviour on PayPal
Serviceswebsite.
DemandGen AG (Germany)
To execute e-mail
marketing
campaigns
Name, email address,
phone number, type of
account, type, and
nature of PayPal
Services offered or
used and relevant
transaction
information.
Business support services - b2s, SAS (France),
Foule Access SAS (France)
To store
merchants' contact
information for
marketing
communications to
those merchants.
Name of the merchant,
name of the contact
person, address, email
address, phone
number, merchant
website URL.
Consultix (France and Spain) and Quadro Srl
(Italy)
To host information
provided by
merchants and
display part of this
information on the
pages of the
PayPal website
listing websites
All information
provided by merchants
in connection with their
use of these pages of
the PayPal website
(including in particular
name of the merchant,
name of the contact,
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
41 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
accepting PayPal
and proposing
special offers to
PayPal users.
email address, logo
and information
relating to the
promotion(s) offered to
PayPal users).
Appnexus, Inc. (US), BlueKai, Inc. (US),
Conversant GMBH (Germany), Google Ireland,
Ltd. (Ireland),DoubleClick Europe Ltd (UK),
Adobe Systems Incorporated.
To execute
retargeting
campaigns in order
to deliver
personalised
advertising.
Anonymous ID
generated by cookies,
pixel tags or similar
technologies
embedded in
webpages
Criteo SA (France)
To execute
retargeting
campaigns in order
to deliver
personalised
advertising.
Anonymous ID
generated by cookies,
pixel tags or similar
technologies
embedded in
webpages and emails
delivered to users.
Linkedin Ireland Limited (Ireland)
To execute
retargeting
campaigns in order
to deliver
personalised
advertising.
Encrypted e-mail
address associated
with PayPal users
(without indicating
account relationship).
Conversant Inc. (USA)
To execute and
measure
retargeting
campaigns in order
to identify visitors
and redirect them
though
personalised
PayPal Account ID (as
appropriate) as well as
device ID used by a
specific person,
content of
advertisements to be
delivered and
segmentation in a user
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
42 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
advertising
campaigns.
group for
advertisement
purposes.
StrikeAd UK Ltd. (UK), Ad-x Limited (UK), Criteo
Ltd. (UK), Criteo Singapore Pte. Ltd
To execute and
measure
retargeting
campaigns in order
to segment users
for PayPal Here
marketing
campaigns.
Anonymous cookie ID,
Advertising ID, and
device ID to segment
user groups for
marketing purposes.
Fiksu, Inc. (US)
To execute and
measure
retargeting
campaigns in order
to segment users
for marketing
campaigns
involving PayPal
mobile
applications.
Device ID used for
Apple’s iOS operating
system when a user
installs an application,
signs up for the
PayPal Services, logs
in, checks in, or sets a
profile picture.
Nanigans, Inc. (US
To execute
retargeting
campaigns in order
to deliver
personalised
advertising.
Advertising ID
associated with Apple
iOS devices when a
user installs an
application,
relaunches an
application, signs up
for the PayPal
Services, logs in,
checks in, checks their
balance, saves an
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
43 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
offer, successfully
completes a
transaction, sets a
profile picture, or
makes other account
changes in or related
to the use of the
application.
Heaven SAS (France)
To execute
marketing
campaigns for
merchants.
Name of merchant,
merchant website
URL, description of
item purchased and
price of item.
Tenthwave Digital, LLC (USA)
To notify winners
and prize fulfillment
for winners of
survey
sweepstakes
Name and email
address, for
sweepstakes winners
and alternates only.
Sotiaf Telematiques Associes SAS (France)
To store user data
for marketing
campaigns and to
execute direct
marketing
campaigns.
Name, email address,
and phone number.
2engage (Germany) and Quo Vadis (Germany)
To conduct market
surveys.
Name, company
name, address,
telephone number,
domain name, e-mail
address, type and
nature of use of
PayPal services,
market segment and
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
44 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
generalised
categorisation of
company size and
information on
participation in earlier
surveys.
Facebook, Inc (USA), Facebook Ireland Limited
(Ireland) and Twitter, Inc. (USA)
To show relevant
advertisements to
Facebook and
Twitter users (as
the case may be).
Encrypted e-mail
address associated
with PayPal users
(without indicating
account relationship).
SurveyMonkey Spain, Sucursal em Portugal
(Portugal) and SurveyMonkey.com, LLC (USA)
To assist in
carrying out user
surveys.
Name, email address
and details of
customer campaign
interaction.
Marketing and Planning Systems, LLC. USA
(USA), Dynamic Logic, Inc. (USA), GfK Custom
Research LLC (USA), Millward Brown, Inc.
(USA) and Radius Global Market Research, LLC
(USA)
To conduct
customer service
and marketing
surveys
Name, email address,
type of account, type
and nature of PayPal
services offered or
used, and relevant
transaction information
Oracle America Inc. (USA),
Oracle Corporation UK Ltd
To develop,
measure and
execute marketing
campaigns.
Name, business
name, address and
registration number of
merchant, name, job
title, email address,
phone number of
merchant’s contact
person, merchant
website URL, PayPal
account number, third
party applications
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
45 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
used by the merchant,
behaviour on PayPal
website.
Nanigans, Inc. (USA), Fiksu, Inc. (USA), Ad- X
Limited (UK); Criteo Ltd. (UK), Criteo Singapore
Pte. Ltd
Help identify
behaviour in the
mobile app in order
to guide decision
about targeted
marketing; to help
efficiently handling
and optimising
mobile campaigns
on social networks
and elsewhere in
the web
Anonymous cookie ID,
Advertising ID, and
Device ID used by a
specific person, events
in the mobile app
about the use of the
mobile app by a
specific user
(including, without
limitation, login,
successful completion
of the transaction), but
no payment and
financial information
details.
Content of
advertisements to be
delivered to specific
users and, as
appropriate,
segmentation group to
which such person
belongs to for
advertisement
purposes.
Zeuner S.p.A. (Italy), Accueil Srl (Italy) and
CallCenterNet Italy s.r.l. (Italy)
To store
merchants' contact
information for
marketing
communications to
Name of the merchant,
name of the contact
person, address, email
address, phone
number, merchant
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
46 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
those merchants. website URL.
Purepromoter Ltd t/a Pure360
To send service
related and
(depending on opt-
in settings)
promotional SMS
messages to
PayPal users.
Mobile Number, name,
address, email
address, business
name, business
contact details,
domain name, account
status, account type,
account preferences,
type and nature of the
PayPal services
offered or used and
relevant transaction
and account
information
Iris (Germany)
To develop,
measure and
execute marketing
campaigns.
Name, business
name, address and
registration number of
merchant/partner,
name, job title, email
address, phone
number of merchant’s
contact person,
merchant website
URL, PayPal account
number, third party
applications used by
the merchant,
behaviour on PayPal
website.
OC&C Strategy Consultants Limited (UK)
To conduct market
research and
develop insight
Anonymized account
and transaction
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
47 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
information
Operational services
Kanzlei Dr. Seegers, Dr. Frankenheim & Partner
Lawyers (Germany, Austria, Switzerland),
Akinika Debt Recovery Limited (UK), Capita Plc
(UK), Compagnie Francaise du Recouvrement
(France), Clarity Credit Management Solutions
Limited (UK),; EOS Solution Deutschland GmbH
(Germany), EOS Aremas Belgium SA/NV
(Belgium), EOS Nederland B.V. (Netherlands),
Arvato Infoscore GmbH (Germany), Infoscore
Iberia (Spain), , SAS (France), Transcom
WorldWide S.p.A. (Italy), Transcom Worldwide
SAS (Tunisia), Intrum Justitia S.p.A. (Italy),
To collect debt.
Name, address, phone
number, account
number, date of birth,
email address,
account type, account
status, last four digits
of financial
instruments account,
sort code, account
balance, details of
account transactions
and liabilities, name of
funding source
provider and copies of
all correspondence in
each case relating to
amounts you owe (or
another person owes)
to us.
KSP Kanzlei Dr. Seegers (Germany), BFS Risk
& Collection GmbH (Germany); HFG
Hanseatische Inkasso- und Factoring-
Gesellschaft (Germany),BFS Risk and Collection
GmbH (Germany), Team 4 Collect (Spain),
Arvato Polska (Poland), BCW Collections Ireland
Ltd (Ireland), S.C. Fire Credit S.R.L. (Romania),
Gothia Financial Group AB (Sweden), Gothia AS
(Norway), Gothia A/S (Denmark), Gothia Oy
(Finland), Credit Solutions Ltd (United Kingdom).
To collect debt; to
handle reporting to
credit reference
agencies about
defaulting
customers.
Name, address, phone
number, account
number, date of birth,
email address,
account type, account
status, last four digits
of financial
instruments account,
sort code, account
balance, details of
account transactions
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
48 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
and liabilities, name of
funding source
provider, applicable
details of account
behaviour and copies
of all correspondence
(including without
limitation, all
correspondence
relevant for reporting
to credit reference
agencies) in each
case relating to
amounts you owe (or
another person owes)
to us.
Begbies Traynor Group plc (UK), Moore
Stephens LLP (UK), Moore Stephens Ltd (UK),
Moore Stephens International Ltd (UK),
Moorhead James LLP (UK), Comas Srl (Italy),
RBS RoeverBroennerSusat GmbH & Co. KG
(Germany), LLC Elitaudit (Russia), National
Recovery Service (Russia).
To investigate
(including, without
limitation, to carry
out asset and/or
site inspections
and/or business
evaluations) and/or
collect (and/or
assist with the
collection of) debt
from potentially
and actually
insolvent
customers
Name, address, phone
number, account
number, date of birth,
email address,
account type, account
status, last four digits
of financial
instruments account,
sort code, account
balance, details of
account transactions
and liabilities, name of
funding source
provider and copies of
all correspondence, in
each case relating to
amounts you owe (or
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
49 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
another person owes)
to us.
Webbank (USA)
Only for customers
who are also
customers of Bill
Me Later, Inc.: to
help with
accounting and
recovery services
Name, address, phone
number, account
number, date of birth,
email address,
account type, account
status, last four digits
of financial
instruments account,
sort code, account
balance, details of
account transactions
and liabilities, and
name of funding
source provider.
Digital River Inc. (USA) and Research in Motion
Limited (USA)
To enable you to
access and use
PayPal via a
mobile device (for
example mobile
phone or PDA).
Applicable details of
your account
information which are
transmitted as part of
your use of PayPal via
a mobile device.
mediafinanz AG (Germany)
To collect debt, to
request and
proceed
information from
and to Schufa,
Buergel and other
credit reference
and fraud agencies
for PayPal
Name, address, phone
number, account
number, date of birth,
business name, email
address, account type,
account status, last
four digits of financial
instruments account,
account balance,
details of account
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
50 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
transactions and
liabilities, name of
funding source
provider, credit score
received from agency,
account performance
data
Zyklop Inkasso Deutschland GmbH (Germany),
PNO inkasso AG (Germany), Hanseatische
Inkasso-Treuhand GmbH (Germany)
To collect and
manage debt, to
support collections
teams in case of
insolvent
customers
Name, address, phone
number, account
number, email
address, account type,
account status, last
four digits of financial
instruments account,
sort code and name of
funding source
provider, account
balance, date and
amount of last
payment, results of
creditworthiness
checks
Informa Solutions GmbH (Germany)
To request and
proceed
information from
and to Schufa,
Buergel and other
credit reference
and fraud agencies
in and from and to
ID Checker
Name, date of birth
business name, legal
form, address, email
address, company
registration number
and VAT number.
For the purpose of
verification of identity
also: other information
contained in
documents requested
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
51 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
by PayPal for Risk /
Compliance purposes.
For customers with a
German PayPal
account also: phone
number, length of time
at address, length of
time in business,
length of time with
PayPal, funding
instrument including
bank account and
credit /debit card
details and relevant
transaction
information, credit
score received on
behalf of PayPal from
a credit reference
agency, account
number, account type,
account status,
account balance,
details of account
transactions and
liabilities, negative
account performance
data.
P K Consultancy Limited (UK)
To assess risk and
help detect and
prevent potentially
illegal acts and
violations of
Name, address, phone
number, account
number, email
address, account type,
last four digits of
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
52 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
policies. financial instruments
account, account
balance, details of
account transactions
and liabilities, account
status and account
performance
information as
required for the
Purpose
Robertson Taylor Insurance Brokers Limited
(UK)
Consultation with
respect to risk
assessment of
specific merchants
and merchant
transactions
Name, address, phone
number, account
number, business
contact details,
domain name, email
address, account type,
account balance,
details of account
transactions and
liabilities, account
status and account
performance
information as
required for the
Purpose.
Yesmail Inc. (USA), Responsys (USA),
Silverpop Systems Inc. (USA) and e-Dialog, Inc.
(USA), Salesforce.com, Inc. (USA), Oracle
America Inc. (USA), Adobe Systems
Incorporated (USA), Teradata Corporation
To fulfil email
operations in
respect of the
PayPal services
(including, but not
limited to,
operations,
customer services,
Name, address, email
address, business
name, business
contact details,
domain name, account
status, account type,
account preferences,
type and nature of the
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
53 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
collections,
marketing
programmes and
promotions).
PayPal services
offered or used and
relevant transaction
and account
information.
Blue Media S.A. (Poland)
To verify identity
and ensure that a
user is a PayPal
account holder. To
process instant
funding requests
made by a user
through the Blue
Media services.
Name and email
address.
Consultix GmbH (Germany)
To assist in the
creation of PayPal
Business Accounts
for merchants on-
boarding through
their bank's or
other contract
partner payment or
service gateway.
All information
provided by the
merchant (directly or
via his/her bank or
other contract partner)
for the purpose of
creating his/her
PayPal business
account (including
without limitation email
address, address,
business name,
business contact
details and bank
account details).
Akamai Technologies Inc. (USA)
Content delivery
network – to
deliver PayPal
User IP address and
cookies.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
54 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
page content from
local servers to
users.
azionare GmbH (Germany)
To distribute prizes
in prize promotions
on Facebook.
Name, email address.
ITELLIUM mobile Solutions GmbH (Germany);
CartaSi S.p.A - Gruppo ICBPI (Italy)
To assist in the
production of
innovative payment
methods (e.g.
applications) and
processing of
payments through
such innovative
payment methods.
All account
information.
Trustwave Holdings Inc. (USA)
To provide PCI
compliance
validation services
for merchant
accounts and
merchant
integrations.
Business name,
address, account
number, merchant
type, compliance
program used, PCI
Level, PCI Status, PCI
Expiry, name, email
address, phone
number of merchant’s
contact person
Zoot Enterprises, Inc. (USA), Zoot Deutschland
GmbH (Germany), Zoot Enterprises Limited
(UK)
To process
technical
applications and to
provide a data and
document gateway
for account review,
testing and vetting
All account information
and documents
supplied by customers
such as proofs of
identity and address,
ownership of a funding
instrument, or other
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
55 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
purposes, and to
exchange user
information and
images of
documents proving
identity, address
and ownership of
funding instrument
with contracted
fraud and credit
reference
agencies.
documents requested
by PayPal and the
data contained therein
for Risk / Compliance
Credit purposes.
RR Donnelley and Sons Company (USA)
To provide printing
services such as
statements and
other printed
materials
Name, address, email
address, and account
information
Scorex (UK) Limited (UK)
To provide a
technology solution
to allow PayPal to
process, send and
receive credit
information of
users via its
contracted credit
reference
agencies.
Name, address, email
address, date of birth,
length of time at
address, phone
number, legal form,
length of time in
business, company
registration number,
VAT number (if
appropriate).
OXID eSales AG (Germany)
Services in
connection with the
development and
operation of a
payment system
All account information
and transaction
information (as
appropriate).
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
56 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
for stationary trade
(point of sale)
Ordermotion, Inc. (USA)
To collect data and
create/deliver
(direct to customer)
orders for the
PayPal Here
product (including,
without limitation,
the PayPal Here-
enabled device).
Name, address, email,
phone number, credit
card information and
PayPal Payer ID.
Ingram Micro, Inc. (USA) and Ingram Micro (UK)
Limited (UK)
To act as PayPal's
fulfilment
distributor for the
PayPal Here
product (including,
without limitation,
the PayPal Here-
enabled device).
Name and address.
Interxion Datacenters B.V.
To provide data
centre operations
support for the Bill
Safe credit
product.
All relevant account
information and
transaction information
(as appropriate).
Lattice Engines, Inc.
To develop and
optimize predictive
models.
Name of the merchant,
name of the contact
person, address, email
address, merchant
website URL
Interact CC Ltd (UK)
Providing
assistance with
PayPal service to
Customer name,
business name, phone
numbers, contact
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
57 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
customers email, website,
business industry,
shipping details, card
details for the payment
The unbelievable Machine Company GmbH
Hosting BillSafe
application on its
servers
All Account
information.
Group companies
PayPal Inc. (USA)
Acting on behalf of
PayPal for the
purposes of storing
and processing of
Account
information.
All Account
information.
PayPal Europe Services Limited (Ireland),
PayPal Malaysia Services Sdn Bhd (Kuala
Lumpur), PayPal Israel Ltd (Israel), PayPal India
Private Limited (India), PayPal (UK) Ltd (UK),
PayPal France S.A.S. (France), PayPal
Deutschland GmbH (Germany), PayPal Spain
SL (Spain), PayPal Italia Srl (Italy), PayPal
Nederland BV (Netherlands), PayPal European
Marketing SA (Switzerland), PayPal Polska Sp
Zoo (Poland), PayPal Bilisim Hizmetleri Limited
Sirketi (Turkey), PayPal International Sarl
(Luxembourg), PayPal SE (UK), Bill Me Later
Inc. (Germany), PayPal Information
Technologies (shanghai) Co., (China), PayPal
Australia Pty Limited (Australia), PayPal
Charitable Giving Fund (USA), PayPal Giving
Fund UK (UK), Tradera AB (Sweden),
Acting on behalf of
PayPal for the
purpose of
customer support,
risk assessment,
compliance and/or
other back office.
All Account
information.
PayPal Pte. Ltd. (Singapore) Acting for the All Account
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
58 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
account of PayPal
by entering into
and performing
non-customer
contracts which
involve customer
data.
information.
Commercial partners
eBay Inc. (USA), eBay Europe S.à r.l.
(Luxembourg), eBay Services S. à r.l.
(Luxembourg), eBay International AG
(Switzerland), eBay Corporate Services GmbH
(Germany), eBay France SAS (France), eBay
(UK) Limited (UK), eBay CS Vancouver Inc.
(Canada), eBay Partner Network Inc. (USA),
eBay Internet Support (Shanghai) Co Ltd
(China), eBay Enterprise Marketing Solutions
(USA) (formerly GSI Commerce, Inc (USA),
VendorNet Inc (USA), PepperJam Network
(USA), GSI Media Inc. (USA), M3 Mobile Co.,
Ltd. (Korea), MBS (USA), ClearSaleing (USA),
True Action Network (USA), True Action Studio
(USA)), GumTree.com Limited (UK), Kijiji
International Limited (Ireland), Kijiji US Inc.
(USA), mobile.de & eBay Motors GmbH
(Germany), Shopping.com Inc. (USA), Shopping
Epinions International Limited (Ireland),
Marktplaats B.V. (Netherlands), Private Sale
GmbH (Germany), StubHub, Inc. (USA), Viva
Group, Inc. (USA), StubHub Europe S.à r.l.
(Luxembourg), StubHub Services S.à r.l.
(Luxembourg), Viva Group, Inc. (USA),
ProStores Inc. (USA), MicroPlace, Inc. (USA),
To provide joint
customers content
and services
(including, but not
limited to
registration,
transactions,
failover for carrier
billing accounts,
and customer
support), to assess
risk, or to help
detect, prevent
and/or remediate
fraud, or other
potentially illegal
acts and violations
of policies, and to
guide decisions
about their
products, services
and
communications.
All Account
information.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: July 1, 2015
59 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.
Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed
Internet Auction Co., Ltd. (Korea), Via-Online
GmbH (Germany), Zong Inc.(USA) and
X.commerce, Inc. (USA). eBay Europe Services
Limited (Ireland), eBay GmbH (Germany)
Agencies
CSSF (Luxembourg), CNPD (Luxembourg),
Financial Ombudsman Service (UK),
Altroconsumo (Italy), European Consumer
Centre Network organisations (located in
Austria, Belgium, Bulgaria Czech Republic,
Cyprus, Denmark, Estonia, Finland, France,
Germany, Greece, Hungary, Iceland, Ireland,
Italy, Latvia, Lithuania, Luxembourg, Malta,
Netherlands, Norway, Poland, Portugal,
Romania, Slovakia, Slovenia, Spain, Sweden,
and the UK), Les Mediateurs du Net (France),
Risolvi Online (Italy) and BaFin (Germany)
To provide the
Agencies listed
with information
within their
authority (upon
their request) and
to respond to
queries and/or
investigations
instigated by users
or other
stakeholders in the
countries where
they have
jurisdiction.
All account information
With respect to the column titled, "Purpose", each third party, with the exception of the regulatory
agencies, certain of the payment processors and credit reference and fraud agencies and group
companies referred to at the end of this table, is carrying out the purpose to fulfil obligations which
PayPal has contracted with the entity to fulfil. The regulatory agencies are carrying out their purpose
in accordance with their regulatory objectives and requirements. Where explicitly specified in the
table, the payment processors and credit reference and fraud agencies may use the information in
their respective databases, and forward information to third parties for the purposes of fraud
prevention and the assessment of creditworthiness, in accordance with their respective terms.